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Note—Reclaiming Brown's Vision

A New Constitutional Framework for Mandating School Integration

By Anne Randall

The Brown v. Board of Education decision declared state-imposed segregation of public schools unconstitutional. The U.S. Supreme Court mandated integration by calling for school boards affirmatively to dismantle segregated school systems. However, the Court does not require remedies in cases of de facto desegregation, while it may remedy de jure segregation. The Court should examine whether state actions other than those of the school board, such as zoning and urban planning, create residential segregation and contribute to the current state of school desegregation.

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